On obtaining - and keeping - the now-tougher-to-get C-TPAT

Another program rushed into existence after 9/11 was the safe shipper program; DHS has allocated so few resources to the program, that Congress suspended it; last March the administration toughened the program requirements, so applicants may want to re-educate themselves about it

So you are interested in getting and keeping a C-TPAT certification? Let’s step back a bit. C-TPAT stands for the Customs-Trade Partnership Against Terrorism. The program has its critics, and Congress discovered it did not exactly get off to a good start because DHS allocated ridiculously tiny resources to it, but still, the program has gained momentum. Nearly 10,000 importers have applied for C-TPAT certification, and new applications come in every month.

Obtaining and keeping the certification has become harder since last March, after shocked legislators discovered that overworked and desperate-to-reduce-the-backlog DHS employees offered certifications to importers without any background checks. Congress then mandated that the Bureau of Customs and Border Protection (CBP) introduce new and stiffer standards. These new standards, which apply to new applicants and current C-TPAT members alike (many of which subjected to but perfunctory background checks, if any) require that CBP officers must now be able to confirm, among other things, that foreign suppliers, vendors, and contractors are performing seven-point container inspections, documenting their procedures for issuing keys, changing passwords, and an array of other best security practices.

As part of the program, CBP requires C-TPAT members to prepare a Security Profile which outlines the steps they are taking and to conduct ongoing internal audits to ensure that their employees, vendors, suppliers, and trading partners actually follow enhanced policies and procedures. Congress demanded that CBP not rely entirely on the honor system: The bureau has established what it calls a “validation” process, allowing CBP supply-chain security specialists to meet with company representatives, and visit foreign and domestic sites to verify that everyone in a company’s supply chain is following the practices outlined in the member’s Security Profile (Note: CBP is under increasing criticism to assign more inspectors to this phase of the operation). If the inspections reveal significant problems, CBP can suspend or even revoke the importer’s benefits.

Still interested in the C-TPAT? Then you should read Barry Brandman’s helpful two-part article on the subject.

-See Barry Brandman’s article - part one and part two; for details about the program see the Customs and Border Protection Web site